Big Win for Organic Dairy

Final Origin of Livestock Rule Levels the Playing Field for Organic Dairy Farmers

In a long-awaited and hard-won victory for organic integrity, the USDA has finally passed the Origin of Livestock Rule, closing the loophole that previously allowed dairy farmers to consistently raise livestock conventionally (i.e. more cheaply) and transition them to organic later in life. The ability to continuously transition conventially raised livestock into an organic operation has put some farmers at an economic advantage over others, like those here in Vermont, who haven't taken advantage of this loophope. 

Vermont Organic Farmers LLC (VOF), the organic certification agency owned by NOFA-VT, interprets USDA organic rules with the input of organic farmers, historically leading to high-integrity interpretations. VOF, and many other certifiers, have interpreted the rules around livestock transition to mean that conventional dairy farmers converting their operations to organic have a one-time opportunity to transition their whole, distinct herd to organic production. After that transition, VOF has required that farmers raise all animals organically from the last third of gestation (meaning before birth).

The final Origin of Livestock Rule released by USDA last week clarifies that VOF's interpretation is the corrent one, and ensures our local organic dairy farmers are competing on a more level playing field and improves the integrity of the organic system nationwide.  USDA created a helpful fact sheet summarizing the rule's provisions. 

Specifically, the rule includes the following important clarifications: 

  • A dairy livestock operation transitioning to organic, or starting a new organic farm, is allowed to transition non-organic animals one time.
  • Organic dairies are prohibited from sourcing any transitioned animals. Once a dairy is certified organic, animals must be managed as organic from the last third of gestation. Variances may be requested by small businesses for specific scenarios.


The rule finalized last week was first proposed by USDA in 2015, and has been stalled since, despite widespread agreement and advocacy from the organic community that it was needed. Specifically clarifying that dairies are prohibited from purchasing or selling transitioned animals as organic is a critical piece of closing this loophole, and something NOFA-VT and VOF have advocated for in our comments on the rule. 

To learn more about the rule and its impact on Vermont producers, check out recent media coverage from VPR and VTDigger.